EPA’s Clean Power Plan

Power Experts 2014 - Atlanta

November 5, 2014

Dr. Kenneth Mitchell

U.S. Environmental Protection Agency

Atlanta, GA
• EPA Actions on Climate 

Change

• EPA’s Clean Power Plan

Outline

www.epa.gov/climatechange and www.epa.gov/cleanpowerplan
U.S. GHG Pollution

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EPA Actions to Reduce Carbon Pollution

• Building a 21st century transportation 

sector

• Cutting energy waste in homes, 

businesses, and factories

• Reducing methane and HFCs

• Preparing the U.S. for the impacts of 

climate change

• Helping lead international efforts to 

address global climate change

• Reducing carbon pollution from power 

plants 

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President’s June 2013 Directive to EPA:

Develop carbon pollution standards, regulations or guidelines, as 

appropriate, for:

1. New power plants

• Proposed January 8, 2014

2. Modified and reconstructed power plants

• Proposed June 2014

• Final June 2015

3. Existing power plants

• Proposed Guidelines June 2014

• Final Guidelines June 2015

• State Plans due June 2016

GHG NSPS Requirements for Fossil Fuel-Fired Power Plants

http://www.epa.gov/cleanpowerplan

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• EPA conducted a robust pre-proposal stakeholder engagement process

oParticipated in meetings with over 300 utility, consumer, labor 

and environmental groups since June 2013

oHeld 11 public listening sessions around the country

3,300 people attended

More than 1,600 people offered oral statements

• Reached out to all 50 states

o Some states noted their programs to address 

carbon evolved because of:

The need to address carbon pollution

Electric system that is dynamic, and in 

the midst of market changes

Modernizing the power sector is good 

for the economy

• Common themes included reliability, flexibility, affordability, time for 

plans and implementation

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Early Outreach Informed This Proposal
This Clean Power Plan (CPP) proposal will: 

• Reduce carbon pollution from existing power plants, for which there are currently no 

national limits

• Maintain an affordable, reliable energy system and will help move us toward a cleaner, 

more stable environment for future generations

• By 2030, reduce nationwide carbon dioxide emissions, from the power sector by 

approximately 30% from 2005 levels, with significant reductions to begin by 2020

• Cut hundreds of thousands of tons of harmful particle pollution, sulfur dioxide and 

nitrogen oxides as a co-benefit

• Proposal will avoid an estimated 2,700 to 6,600 premature deaths and 140,000 to 150,000 asthma 

attacks in 2030

• Provide important health protections to the most vulnerable, such as children and older 

Americans

• Lead to health and climate benefits worth an estimated $55 billion to $93 billion in 

2030

• From soot and smog reductions alone, for every dollar invested through the Clean 

Power Plan - - American families will see up to $7 in health benefits 

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Summary - 111(d) Existing Power Plant Proposal
• Build on actions states, cities and businesses across the country are already 

taking to address the risks of climate change

• Spur investment in cleaner and more efficient technologies, creating jobs and 

driving innovation

• Require a reasonable emission reduction glidepath starting in 2020

• Provide a flexible timeline—up to 15 years from guideline issuance—for all 

emission reduction measures to be fully implemented in 2030

o Recognizing that investments in infrastructure can take time to put in place and 

o Avoiding stranded assets

• Provide an array of tools states can use to formulate approvable plans.

Summary - 111(d) Existing Power Plant Proposal

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http://www.epa.gov/cleanpowerplan
Other Benefits

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Electricity bills down 

8% in 2030

$0

$20

$40

$60

$80

$100

$120

1990 1995 2000 2005 2010 2015 2020 2025 2030

Monthly Residential Electricity Bills (2011$)

Historical - Converted to 2011$ Base Case Clean Power Plan
After Proposal, Coal & Natural Gas Remain Leading Sources 

of Electricity Generation

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Each more than 30% of projected generation in 2030

Coal

31%

Natural Gas

32%

Other Fuel

37%
Background: Clean Air Act Section 111(d)

Best System of Emission Reduction

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• Previous EPA rules under this section of the 

Clean Air Act have considered “add-on” control 

technologies – like scrubbers -- that are technically 

feasible to deploy at virtually any facility

• In contrast, there are a wide variety of ways to 

reduce carbon pollution that are commercially 

available, technically feasible, and cost effective

• The opportunities vary from state to state, depending on how electricity is 

generated, energy infrastructure, and other factors

• In this proposal, EPA took an approach that viewed the Clean Air Act factors in 

determining Best System of Emission Reduction (BSER) in light of the 

interconnected nature of power generation

BSER factors

• Costs

• Size of reductions 

• Technology

• Feasibility

http://www.epa.gov/cleanpowerplan
EPA Establishes a Goal for Every State

• EPA analyzed the practical and affordable strategies that states and utilities are already 

using to lower carbon pollution from the power sector 

• Proposed goals are based on a consistent national formula, calculated with state and 

regional specific information 

• Each state goal is expressed as a rate (pounds of CO2 per MWh) – a statewide number 

for the future carbon intensity of covered existing fossil-fuel-fired power plants in a 

state

• The state rate goal is calculated to account for 

the mix of power sources in each state and the 

application of four “building blocks” that make 

up the best system of emission reduction

• States will need to meet an interim goal and 

a final goal

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Building Block Strategy EPA Used to 

Calculate the State Goal

Maximum Flexibility:

Examples of State 

Compliance Measures

1. Make fossil fuel-fired

power plants more 

efficient

Efficiency Improvements • Efficiency improvements

• Co-firing or switching to 

natural gas

• Coal retirements

• Retrofit carbon capture and 

sequestration (CCS)

2. Use lower-emitting power 

sources more

Dispatch changes to 

existing natural gas 

combined cycle (CC)

• Dispatch changes to existing 

natural gas CC

3. Build more zero/lowemitting energy sourcesRenewable Energy

Certain Nuclear

• New NGCC

• Renewables

• Nuclear (new and up rate)

• New coal with CCS

4. Use electricity more 

efficiently

Demand-side energy 

efficiency programs

• Demand-side energy 

efficiency programs

• Transmission efficiency 

improvements

• Energy storage

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Flexibilities Available To States

• Timing

o Up to 15-year window in which to plan for and achieve reductions in carbon pollution 

o Up to two or three years to submit final plans 

• Form of goal

o States can use either a rate-based or mass-based goal

• Single or multi-state plans

o States can collaborate and develop plans on a multi-state basis

• Selection of measures 

o States will choose how to meet the goal through whatever

collection of measures reflects its particular circumstances 

and policy objectives

o State measures may impact and, in fact may be explicitly 

designed to reduce, CO2 emissions from utilities on a regional 

basis

o EPA would support building off existing reduction programs 

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http://www.epa.gov/cleanpowerplan
States Have Flexibility

Basis for state goal –

Potential emissions 

pathway reflecting 

EPA’s analysis

 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029

 

A state can choose any trajectory 

of emission improvement as long 

as the interim performance goal is 

met on average over 10 years, and 

the final goal is met by 2030

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Carbon emissions from affected power 

plants in an example state

As an example, states could do less in the early years, and more in the later 

years, as long as on average it meets the goal

Timing of Power Plant Emission Reductions
When States Plan, They Can...

• Look broadly across the power sector for strategies that get reductions

• Choose to rely to varying degrees on measures that EPA used to calculate the goal, 

or on other measures that were not part of the state goal-setting analysis

• Invest in existing energy efficiency programs or create new ones

• Consider market trends toward improved energy efficiency and a greater reliance on 

lower carbon energy

• Tap into investments already being made to upgrade aging infrastructure

• Expand renewable energy capacity

• Integrate their plans into existing power sector planning processes

• Design plans that use innovative, cost-effective regulatory strategies

• Develop a state-only plan or collaborate with each other to develop plans on a multistate basis

• Decide how to treat plants nearing the end of their useful life and how to help plants 

avoid “stranded investments”

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By June 30, 2016

State submits initial multistate plan and request for 2-

year extension

EPA reviews initial plan 

and determines if 

extension is warranted

by June 30, 2017

State submits progress 

report of plan

by June 30, 2018

States submits multistate plan

State submits Negative Declaration

State submits complete implementation Plan by June 30, 2016

State submits initial Plan by June 30, 2016 and request 1-year extension

State submits initial multi-state Plan by June 30, 2016 and request 2-year extension

Emission 

Guideline 

Promulgation

June 1, 2015

by June 30, 2016

State submits negative 

declaration

EPA publishes FR notice

by June 30, 2016

State submits plan

by June 30, 2016

State submits initial plan 

and request for 1-year 

extension

EPA reviews initial plan and 

determines if extension is 

warranted

by June 30, 2017

State submits complete plan

2015 2019

Proposed Implementation Timeline

Compliance 

period begins

2020

2020

EPA reviews plan and 

publishes final decision 

within 12 months on 

approval/disapproval

EPA reviews plan and 

publishes final decision 

within 12 months on 

approval/disapproval

EPA reviews plan and 

publishes final decision 

within 12 months on 

approval/disapproval

2016 2017 2018
Supplemental Proposal

• October 28, 2014 - EPA issued a supplemental proposal to its proposed CPP that 

sets area-specific goals for Indian country and territories

• South Point Energy Center, in Fort Mojave Indian country geographically located within 

Arizona;

• Navajo Generating Station, in Navajo Indian country geographically located within AZ

• Four Corners Power Plant, in Navajo Indian country geographically located within NM

• Bonanza Power Plant, in Ute Indian country geographically located within UT

• Puerto Rico

• Guam

• Two main elements: 

• Emission rate-based goals specific to each area of 

Indian country and U.S. territory that has affected EGUs

• Guidelines for the development, submission, 

and implementation of plans to achieve the goals

• Provides options for meeting those goals in a flexible 

manner that accommodates a diverse range of approaches

Comment Period Closes December 19, 2014 18
Notice of Data Availability (NODA)

• October 28, 2014 - EPA issued a NODA related to the proposed 

CPP

• In this NODA, EPA discusses several issues that have been raised 

by stakeholders, including:

• The trajectory – or glide path – of emission

reductions from 2020 to 2029

• Aspects of the way building blocks

are established

• The way the state goals are calculated

• The NODA is not intended to be a complete summary 

of the wide variety of ideas that have been raised

• The agency has heard many other concepts that are not highlighted in 

this document because they are covered in the June proposal

Comment Period Closes December 1, 2014 19
NODA – Glide Path

• The NODA discusses potential technical challenges described by some 

stakeholders associated with achieving all of the reductions that states would be 

required to make as early as 2020, when the compliance period begins

• Stakeholders have suggested two potential approaches for addressing these 

issues

• Allow credit for early reductions, which could provide flexibility to defer other emission 

reductions until later in the 2020 to 2029 period

• Phasing in building block 2 over time, just as building blocks 3 and 4 are phased in over 

time in the June proposal

• The NODA discusses these approaches that stakeholders have offered and 

explains how EPA’s June 2014 proposal requests comment on the option of early 

reductions

• EPA discusses and is requesting comment both on the concept of phasing in the 

reductions required under building blocks 1 and 2 over time and possible 

approaches to effectuating such a phase-in

http://www.epa.gov/cleanpowerplan 20
NODA - Establishing Building Blocks

• The NODA focuses on two issues raised by multiple stakeholders, including 

states, about certain aspects of the building block methodology: 

• The treatment of natural gas in building block 2

• The treatment of renewable energy in building block 3

• Stakeholders have suggested that the EPA’s Best System of Emission Reduction 

(BSER) determination should recognize that there are additional opportunities in 

the current market to use natural gas beyond those EPA included in the June 

proposal

• Stakeholders have suggested a regional approach to establishing renewable 

energy targets

• In this NODA, the EPA discusses these approaches that stakeholders have 

suggested and requests comment on ways that building block 2 could include 

new natural gas combined cycle (NGCC) units and natural gas co-firing in existing 

coal-fired boilers and ways that state-level, renewable energy targets could be 

set based on regional availability of renewable energy

http://www.epa.gov/cleanpowerplan 21
NODA - Calculating State-specific CO2 Goals

• The NODA addresses two issues raised by some stakeholders, including 

states, regarding the calculation of state-specific CO2goals

• Some stakeholders have offered that the formula for calculating each state's goal 

is not consistent

• Stakeholders have also raised questions about the use of power plant emissions 

data for the single year, 2012

• In the NODA, EPA discusses these issues and requests comment on 

alternative approaches suggested by stakeholders for the goal-setting 

equation

• In addition, EPA is making available data for the years 2010 and 2011 

using the eGRID methodology and requesting comment on alternative 

uses of data sets in calculating the goals

• The 2010 and 2011 datasets will be posted to the docket and are available on 

EPA’s Clean Power Plan website at: http://www2.epa.gov/carbon-pollutionstandards/clean-power-plan-proposed-rule-technical-documents

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Next Steps

• The proposed rule, as well as information about how to 

comment and supporting technical information, are available 

online at: http://www.epa.gov/cleanpowerplan

• EPA held 4 public hearings the week of July 28th in Denver, 

Atlanta, Pittsburgh and Washington, D.C. – over 2,700 people 

attended

• Comments on the CPP proposed rule and NODA are due 

December 1, 2014

• Comments on the proposal should be identified by Docket ID 

Number: 

EPA-HQ-OAR-2013-0602

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Questions?

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